- 1 - HC-KAR NC: 2025:KHC:50376 WP No. 27814 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 2ND DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 27814 OF 2025 (T-IT) BETWEEN: 1. M/S DISTRICT MADAKARI NAYAK ASSOCIATION (R) KAMANBHAVI BADAVANE, CHITRADURGA - 577 501 (SOCIETY REGISTERED UNDER THE MYSORE SOCIETIES REGISTRATION ACT 1960 (MYSORE ACT 17 OF 1960) REPRESENTED BY ITS PRESIDENT SRI. SANDEEP …PETITIONER (BY SRI. JEEVAN J. NEERALGI, ADVOCATE) AND: 1. INCOME TAX OFFICER WARD-1, CHITRADURGA CHITRADURGA - 577 501 2. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT CHITRADURGA - 577 501 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO i) DIRECTION TO QUASH THE IMPUGNED ASSESSMENT ORDER DATED 19/12/2024 BEARING DIN NO. ITBA/AST/S/147/2024- Digitally signed by SHARADAVANI B Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:50376 WP No. 27814 of 2025 25/1071360696(1) FOR THE ASSESSMENT YEAR 2020-21 (ANNX-E) PASSED BY THE RESPONDENTS AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks the following reliefs: "WHEREFORE, the Petitioner prays that this Hon'ble Court may be pleased to: 1. Issue writ of certiorari or any other appropriate writ, order or direction to quash the impugned Assessment Order dated 19/12/2024 bearing DIN No. ITBA/AST/S/147/2024-25/1071360696(1) for the Assessment Year 2020-21 (Annexure-E) passed by the Respondents in the interest of justice and equity. ii. Issue a writ of certiorari or any other appropriate writ, order or direction to quash the impugned Notice dated 30/03/2024 under Section 148 of the Income-Tax Act bearing DIN & Notice No: 41063677155(1) 2 ITBA/AST/S/148- 1/1063677155(1)/2023-24)(Annexure-D) in the interest of justice and equity. iii. Issue a writ of certiorari or any other appropriate writ, order or direction to quash the impugned Order dated 30/03/2024 under Section 148A(d) of the Income-Tax Act bearing DIN & Notice No: ITBA/AST/F/148A/2023-24/1063676840(1) - 3 - HC-KAR NC: 2025:KHC:50376 WP No. 27814 of 2025 [Annexure-Court] in the interest of justice and equity. iv. Pass such other order as this Hon'ble Court deems fit under the circumstances of the case in the interest of justice and equity." 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co- ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order. - 4 - HC-KAR NC: 2025:KHC:50376 WP No. 27814 of 2025 4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed. 5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices issued by the jurisdictional Assessing Officer outside the scope of Section 151-A of the Act stand obliterated. All further proceedings initiated thereto, challenged in these cases would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. - 5 - HC-KAR NC: 2025:KHC:50376 WP No. 27814 of 2025 (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary." 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case (supra). 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. - 6 - HC-KAR NC: 2025:KHC:50376 WP No. 27814 of 2025 (ii)The impugned show cause notices and consequential orders, notices etc., at Annexures- E. D and C dated 19.12.2024, 30.03.2024 and 30.03.2024 respectively are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE BSV List No.: 2 Sl No.: 66/CT-SG